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DOJ Pilot Whistleblower Rewards Program and New AI Initiatives: Implications for Corporate Compliance Programs

A live 90-minute CLE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Thursday, June 27, 2024

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, May 31, 2024

or call 1-800-926-7926

This CLE webinar will guide corporate counsel through the U.S. Department of Justice's (DOJ) pilot whistleblower rewards program and new AI-related initiatives. The panel will discuss the impact of these programs and initiatives on internal compliance and reporting structures and describe what counsel and their clients should be doing now.


Recently, the DOJ announced a new whistleblower pilot program that incentivizes reporting corporate misconduct and financial crimes to the DOJ. It also announced several new AI-related initiatives. These initiatives have important implications for corporate compliance programs.

Under the upcoming pilot program, individuals who help the DOJ uncover significant corporate misconduct or criminal activity previously unknown to the DOJ could receive a portion of the resulting forfeiture of criminal proceeds. The program will fill gaps in the existing federal whistleblower program framework.

The DOJ plans to seek stiffer penalties for criminals who "deliberately misuse AI" to make white collar crime much more serious. In evaluating corporate compliance programs, the DOJ will also consider whether a corporation has made efforts to mitigate risks related to the use of AI.

Listen as our expert panel guides corporate counsel through the DOJ's pilot whistleblower rewards program and new AI-related initiatives. The panel will discuss key focus areas and parameters of the program so that counsel can advise clients on how best to strengthen their corporate compliance programs in response.



  1. Introduction
  2. Whistleblower pilot program focus areas
    1. Criminal abuses of U.S. financial system
    2. Financial corruption outside the jurisdiction of the SEC--e.g., FCPA violations by non-issuers; violations of Foreign Extortion Prevention Act
    3. Domestic corruption, including illegal payments to government officials
  3. Whistleblower pilot program key parameters
    1. Cash payment only when no competing incentive (e.g., qui tam or another federal whistleblower program)
    2. Misconduct reported not previously known to government
    3. Above a certain monetary threshold, which is to be determined
  4. AI-related initiatives
    1. Enhanced penalties for crimes involving deliberate misuse of AI in white collar crime
    2. Effort to integrate AI into Federal Sentencing Guidelines
  5. Implications for corporate compliance programs


The panel will review the following and other important issues:

  • What are the main focus areas of the DOJ's whistleblower pilot program?
  • What parameters will the DOJ use to determine whether to provide rewards to whistleblowers?
  • What should counsel do to ensure their clients' compliance programs are equipped to encourage timely and internal reporting of wrongdoing?


Hockeimer, Henry
Henry E. Hockeimer, Jr.

Partner, White Collar Defense/Internal Investigations Group Leader
Ballard Spahr

Hockeimer’s practice focuses on white collar criminal defense and securities fraud/litigation. He counsels...  |  Read More

Mainoo, Abena
Abena Mainoo

Cleary Gottlieb Steen & Hamilton

Ms. Mainoo has conducted high-stakes investigations involving a range of misconduct (including financial crimes and...  |  Read More

Pugh, Preston
Preston L. Pugh

Partner, Co-Chair False Claims Act Practice
Crowell & Moring

A former Assistant U.S. Attorney, compliance monitor, and Senior Counsel at a Fortune 10 company, Mr. Pugh’s...  |  Read More

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